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Request/Verify Each Access Person’s Annual Holdings Report of Personal Securities

January 9

In general, an investment adviser firm’s code of ethics requires each access person within the firm to submit annually to the firm’s chief compliance officer (“CCO”) or other designee a report of the access person’s current personal securities holdings.

Typically, the report must include the following information:

  • The title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership;
  • The name of any broker, dealer or bank with which the access person maintains an account in which any securities are held for the access person’s direct or indirect benefit; and
  • The date the access person submits the report.

The information within the report must be current (as of a date no more than 45 days prior to the date the report was submitted).

Related Sample Forms

Please review the following sample forms available in the compliance library of RIA Compliance Consultants, Inc.:

  • Insider Trading – Annual Questionnaire of Firm’s Supervised Person’s Affiliation with Public Company


  • Insider Trading – Identifying and Mitigating Risk Checklist


  • Personal Securities Transactions – Annual/Initial Personal Securities Holding Report


  • Personal Securities Transactions – Brokerage Account Disclosure Form


  • Personal Securities Transactions – Letter to Request Duplicate Confirmations & Statements


  • Personal Securities Transactions – Personal Securities Trading Request Form


  • Personal Securities Transactions – Pre-Clearance Form


  • Personal Securities Transactions – Quarterly Personal Securities Transaction Report


  • Personal Securities Transactions – Supervising for Insider Trading Checklist


  • Personal Securities Transactions Form – Non-Access Person Acknowledgment


General Disclosure

The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. This sample compliance calendar event does not necessarily reflect the requirements of your investment adviser firm’s compliance manual. Securities regulations and corresponding deadlines are subject to change, and this calendar event may not reflect the most current requirements.  This calendar event does not create a consulting engagement with RIA Compliance Consultants, Inc. and is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s rules and published guidance for more details and the most current requirements about the topics referenced above.